I have had the privilege of supervising both graduate students and residents and I see the presented changes as having a negative impact on both populations and insufficiently addressing the primary need of improved supervision standards. My following comments address the current proposed changes but are based on the foundation for a call to improved supervision standards.

Graduate Students: Many graduate students find themselves with limited options for sites and the positions at sites often result in an excess of direct hours and at times, excess supervision hours. Setting December 18th as the day that change are made will significantly impact students who anticipated and intentionally worked towards excess internship hours to apply to their residency. I would recommend that if graduate students will not be able to count their internship hours towards residency, that these changes not go into effect until May 2026 so that students can have time to adjust their plans or amount of time they are devoting to achieving hours to count towards residency. 

If the Board would be willing to accept a change, I would recommend a cap on the number of direct and supervision hours that could be used for residency. I would advocate that no more than 100 direct hours and 10 supervision hours (5% of required hours for residency) in excess of Internship hour requirements be applicable to residency. Allowing for some hours eases the burden of costs associated with residency, will help minimally reduce the length of time spent in residency, and also allows for meaningful supervision and clinical growth in residency.

Residents: I would like to echo the comments of Dr. David Mikkelson. Allowing for a lower minimum ratio of 1:7 and a maximum of 1:25 for every quarter affords supervisors and residents the opportunity to provide meaningful and stabilizing supervision in the early stages of residency.